Privacy Policy
This Privacy Policy explains how Sub-Etha Press, an imprint of Icemint LLC, a Wyoming limited liability company (“we,” “us,” “our”), collects, uses, and protects information when you visit subethapress.com (the “Site”) or interact with our services.
We believe privacy policies should be readable by humans, not just lawyers. This one is written in plain language.
Who we are
Sub-Etha Press is an independent publishing imprint operated by Icemint LLC.
Address: 30 N Gould St, Sheridan, WY 82801, USA
Email: privacy@subethapress.com
For purposes of the EU General Data Protection Regulation (GDPR), we are the data controller for personal data collected through this Site.
What we collect
If you visit the Site
We use Cloudflare Analytics, a server-side analytics service built into our DNS and CDN provider. Cloudflare Analytics operates entirely at the network layer. It does not inject any JavaScript into your browser, does not set cookies, does not collect personal data, does not track you across sites, and does not create user profiles. All data is aggregated. No individual visitor can be identified.
Cloudflare Analytics is operated by Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA. Analytics data is processed as part of Cloudflare’s global network infrastructure. No personal data is collected, stored, or transferred for analytics purposes.
What Cloudflare Analytics records: aggregate page views, bandwidth, request counts, country-level traffic distribution, and threat metrics. No IP addresses, device fingerprints, or visitor-level data is retained.
We also use Fathom Analytics, a privacy-first analytics service, to count page views and a small number of anonymous events (such as newsletter sign-ups). Fathom loads a small script in your browser but does not use cookies, does not collect or store personal data, does not create user profiles, and does not track you across sites. All analytics data is aggregated; no individual visitor can be identified. Fathom Analytics is operated by Conva Ventures Inc., Canada.
Our pages load web fonts from Google Fonts. When your browser loads these fonts, your IP address is transmitted to Google LLC (USA), because that is how the font files are delivered to your browser. This happens only so the Site’s typography displays correctly. We do not use Google Fonts to track you, and it is not connected to any advertising or analytics profile.
We do not use Google Analytics, Meta Pixel, or any cross-site tracking technology on this Site.
If you subscribe to our newsletter
When you submit our signup form to request a free resource (such as a configuration pack, a sample chapter, or a launch-day link) or to join our newsletter, we collect:
- Your email address, which you enter in the form.
- UTM parameters and the referring URL from your visit, if they are present. These indicate, in general terms, how you found us — for example, which link or campaign brought you to the page.
Here is what happens when you submit the form. Your submission is first handled by a Cloudflare Worker — a small piece of code that runs on Cloudflare’s network — which passes it to Kit (operated by ConvertKit, LLC, USA), our email service provider. Kit stores your email address and sends you the resource you requested and our newsletter. We add you only on the basis of your consent, and you can unsubscribe at any time using the link in every email we send.
To protect the form from spam and automated abuse, the signup form uses Cloudflare Turnstile. Turnstile processes limited technical signals from your visit (such as your IP address and general browser characteristics) to tell human visitors apart from bots, and it may set a strictly necessary token, cookie, or local-storage entry on your device for that purpose. Turnstile is operated by Cloudflare, Inc., USA. It is used only for spam and bot protection — not to track you or to serve advertising.
If you email us
If you send us an email (press inquiries, general contact, DMCA notices), we retain that correspondence for as long as necessary to respond to your inquiry and for our legitimate record-keeping purposes. We do not add you to any mailing list based on an email you send us.
If you buy our book
We do not process any purchases, payments, or financial information. Our books are sold exclusively through third-party retailers (Amazon.com and its international marketplaces). When you purchase a book, Amazon (or the applicable retailer) is the data controller for your purchase data, payment information, and delivery details. We do not receive, access, or store any of that information.
Amazon may share aggregated, non-identifiable sales data with us (total units sold, geographic region). We never receive your name, address, payment details, or any other personal data from Amazon.
Why we collect it (legal bases)
For visitors in the European Economic Area, we process data under the following legal bases (per GDPR Article 6):
| Data | Legal basis | Purpose |
|---|---|---|
| Aggregated analytics (Cloudflare, Fathom) | Legitimate interest (Art. 6(1)(f)) | Understanding how visitors use the Site to improve content |
| Email correspondence | Legitimate interest (Art. 6(1)(f)) | Responding to inquiries, legal compliance |
| Newsletter email address (and any UTM parameters or referring URL submitted with it) | Consent (Art. 6(1)(a)) | Sending you the resources you requested and our newsletter |
| Technical signals for spam and bot protection (Cloudflare Turnstile) | Legitimate interest (Art. 6(1)(f)) | Protecting the signup form from bots and abuse |
| IP address transmitted when web fonts load (Google Fonts) | Legitimate interest (Art. 6(1)(f)) | Displaying the Site’s typography |
You can withdraw your consent to newsletter processing at any time by unsubscribing; this does not affect the lawfulness of processing carried out before you withdrew it.
Who we share data with
We do not sell, rent, lease, or trade your personal data to anyone. Period.
We share data only with the following service providers, who process it on our behalf:
| Service | Provider | Purpose | Location |
|---|---|---|---|
| Analytics | Cloudflare, Inc. | Server-side aggregated analytics | USA (global network) |
| Analytics | Conva Ventures Inc. (Fathom Analytics) | Cookieless, aggregated web analytics | Canada |
| Form processing | Cloudflare, Inc. (Cloudflare Workers) | Receiving and routing newsletter signup submissions | USA (global network) |
| Spam and bot protection | Cloudflare, Inc. (Cloudflare Turnstile) | Protecting the signup form from bots and abuse | USA (global network) |
| Email delivery | ConvertKit, LLC (Kit) | Storing subscriber email addresses and delivering requested resources and our newsletter | USA |
| Web fonts | Google LLC (Google Fonts) | Serving the Site’s typography (receives your IP address when fonts load) | USA |
| Hosting | Hetzner Online GmbH | Serving the Site | EU (Germany) |
We do not use advertising networks, social media pixels, retargeting services, or any technology that profiles visitors or shares data with third parties for their own purposes.
How long we keep it
- Analytics data: Cloudflare and Fathom retain aggregated analytics data per their respective retention policies. No personal data is collected or stored.
- Newsletter subscriber data: Your email address, together with any UTM parameters or referring URL submitted with your signup, is retained until you unsubscribe or request deletion, after which it is removed from our active mailing list. You can unsubscribe at any time using the link in every email we send.
- Email correspondence: Retained for 2 years after the last communication, then deleted, unless longer retention is required by law (e.g., DMCA notices, legal disputes).
Your rights
For all visitors
You may contact us at privacy@subethapress.com at any time to:
- Ask what personal data (if any) we hold about you
- Request deletion of your data
- Unsubscribe from our newsletter
Additional rights for EU/EEA residents (GDPR)
Under the General Data Protection Regulation, you have the right to:
- Access your personal data (Art. 15)
- Rectification of inaccurate data (Art. 16)
- Erasure (“right to be forgotten”) (Art. 17)
- Restriction of processing (Art. 18)
- Data portability (Art. 20)
- Object to processing based on legitimate interest (Art. 21)
- Withdraw consent at any time for consent-based processing (Art. 7(3))
To exercise any of these rights, email privacy@subethapress.com. We will respond within 30 days.
You also have the right to lodge a complaint with a supervisory authority. If you are in the EU, you may contact the supervisory authority in your country of residence. A list is available at edpb.europa.eu.
Additional rights for California residents (CCPA/CPRA)
Under the California Consumer Privacy Act as amended by the California Privacy Rights Act, California residents have the right to know what personal information is collected, request deletion, and opt out of the sale or sharing of personal information. We do not sell or share personal information as defined by the CCPA/CPRA. To exercise your rights, email privacy@subethapress.com.
Children’s privacy
The Site is not directed to children under 13 (or under 16 in the EU). We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child, we will delete it promptly. If you believe a child has provided us with personal data, please contact us at privacy@subethapress.com.
Security
We use commercially reasonable measures to protect the personal data we process. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
International transfers
If you are located outside the United States and interact with our Site, your information may be transferred to and processed in the United States, where our LLC is registered, and in the other countries where our service providers operate. For EU/EEA visitors, these transfers are made in compliance with GDPR Chapter V, using appropriate safeguards where required.
Changes to this policy
We may update this Privacy Policy from time to time. The revised version will be posted on this page with an updated “Last updated” date. We encourage you to review this page periodically. If we make material changes that affect how we handle your personal data, we will notify newsletter subscribers by email.
Contact
Questions, requests, or complaints about this Privacy Policy should be directed to:
Email: privacy@subethapress.com
Mail: Icemint LLC, 30 N Gould St, Sheridan, WY 82801, USA
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